20101014English Di.pdf

-,,,.,BEFORE THE f-"
"i,.nili...oir-i i L. P'r....l 1: 36lJiV1V ! 1
IDAHO PUBLIC UTILITIES COMMISSlQMo
tJT1Lrr"1 E:S
IN THE MATTER OF THE APPLICATION OF )
PACIFICORP DBA ROCKY MOUNTAIN ) CASE NO. PAc.E-10-7
POWER FOR APPROVAL OF CHANGES TO )
ITS ELECTRIC SERVICE SCHEDULES )
)
)
)
)
)
DIRECT TESTIMONY OF DONN ENGLISH
IDAHO PUBLIC UTILITIES COMMISSION
OCTOBER 14,2010
ALLEGEDLY PROPRIETARY DATA HAS BEEN
DELETED FROM THIS DOCUMENT
1 Q.Please state your name and business address for
2 the record.
3 A.My name is Donn English. My business address is
4 472 W. Washington, Boise, Idaho 83702.
5 Q.By whom are you employed and in what capacity?
6 A.I am employed by the Idaho Public Utilities
7 Commission as a senior auditor in the Utilities Division.
8 Q.What is your educational and experience
9 background?
10 A.I graduated from Boise State University in 1998
11 with a BBA degree in Accounting. Following my graduation,
12 I accepted a position as a Trust Accountant with a pension
13 administration, actuarial and consulting firm in Boise. As
14 a Trust Accountant, my primary duties were to audit the
15 day-to-day financial transåctions of numerous qualified
16 retirement plans. In 1999, I was promoted to Pension
17 Administrator. As a Pension Administrator, my
18 responsibilities included calculating pension and profit
19 sharing contributions, performing required non-
20 discrimination testing and filing the annual returns (Form
21 5500 and attachments). In May of 2001, I became a
22 designated member of the American Society of Pension
23 Professionals and Actuaries (ASPPA). I was the first
24 person in Idaho to receive the Qualified 401 (k)
25 Administrator certification and I am one of approximately
CASE NO. PAC-E-10-0710/14/10 ENGLISH, D. (Di)
STAFF
1
1 ten people in Idaho who have earned the Qualified Pension
2 Administrator certification. In 2001, I was promoted to a
3 Pension Consultant, a position I held until 2003 when I
4 joined the Commission Staff.
5 With the American Society of Pension
6 Professionals and Actuaries, I served on the Education and
7 Examination Committee for two years. On this committee I
8 was responsible fOr writing and reviewing exam questions
9 and study materials for the PA-1 and PA-2 exams
10 (Introduction to Pension Administration Courses), DC-1,
11 DC-2 and DC-3 exams (Administrative Issues of Defined
12 Contribution Plans - Basic Concepts, Compliance Concepts
13 and Advanced Concepts) and the DB exam (Administrative
14 Issues of Defined Benefit Plans). I have also regularly
15 attended conferences and training seminars throughout the
16 country on numerous pension issues.
17 While with the Commission, I have audited a
18 number of utili ties including electric, water and gas
19 companies and provided comments and testimony in several
20 cases that dealt with general rates, accounting issues,
21 pension issues and other regulatory issues. In 2004 I
22 attended the 46th Annual Regulatory Studies Program at the
23 Institute of Public Utilities at Michigan State University
24 sponsored by the National Association of Regulatory Utility
25 Commissioners (NARUC). Since then I have regularly
CASE NO. PAC-E-10-0710/14/10 ENGLISH, D. (Di)
STAFF
2
1 attended NARUC conferences and meetings, primarily the
3
2 meetings of the Subcommittee of Accounting and Finance.
Q.What is the purpose of your testimony in this
5
4 proceeding?
A.The purpose of my testimony in this proceeding is
6 to present and support Staff adjustments to the Company's
7 revenue requirement, specifically adjustments to employee
8 wages and benefits, along with an adjustment to property
9 taxes and a minor adjustment to the Company's revenue to
10 impute fair market value for two subleases at the One Utah
12
11 Center in Salt Lake City.
Q.Are you sponsoring any exhibits in this
14
13 proceeding?
A.Yes, I am sponsoring Staff Exhibit Nos. 104-107.
15 Exhibit No. 104 is a summary of all of the adjustments I
16 propose to the Company's Revenue Requirement. The amounts
17 listed are on a total Company (system) basis and have been
18 provided to .staff witness Vaughn to include in the
19 Regulatory Adjustment Model (RA) and the Jurisdictional
20 Allocation Model (JAM).
21 Q.Please explain the imputed revenue adjustment on
23
22 Exhibit No. 104, line 1.
A.The Company's corporate offices are located at
24 the One Utah Center in Salt Lake City. The Company
25 currently leases 120,610 square feet at an average price of
CASE NO. PAC-E-10-0710/14/10 ENGLISH, D. (Di)
STAFF
3
1 $21.31 per square foot, and subleases some of its space to
2 three major tenants at an average price of $18.48 per
3 square foot. In addition, the Company also sublets office
4 space to the Utah Sports Commission and the Economic
5 Development Commission of Utah for $12.00 per year. Staff
6 believes that it is not appropriate for customers,
7 especially Idaho customers, to subsidize through
8 electrici ty rates the leases for these two Utah Commissions
9 at the below market rate that PacifiCorp has decided to
10 grant to them. The total office space occupied by these
11 two Commissions is 7,689 square feet. I impute revenue of
12 $142,069 at a price of $18.48 per square foot, less the $24
13 annually received for these two sub- leases.
14 Q.Please explain your next adjustment.
15 A.The next adjustment I propose on Exhibit No. 104,
16 line 2, is to remove $1,603,785 (system) from FERC Account
17 925 for Injuries and Damages.
18 Q.What is the basis for this adjustment?
19 A.In its Application, the Company proposed using a
20 three-year average, net of receivables from insurance, of
21 amounts booked into Account 925, Injuries and Damages, for
22 a total of $3,481,634 on a system-wide basis, compared to
23 only $1,877,849 during the 2009 test year.
24 Q.Has the Company used the three-year average for
25 Injuries and Damages in the past?
CASE NO. PAC-E-10-0710/14/10 ENGLISH, D. (Di)
STAFF
4
1 A.Yes, however, none of those general rate cases
2 went to a full hearing where the Commission has made a
3 ruling on the issue. Staff will occasionally support the
4 use of averages for accounts that show volatility from year
5 to year that are beyond the Company's control. However,
6 when it comes to Inj uries and Damages, each individual
7 entry into that account is, by its very nature, an
8 extraordinary and hopefully non-recurring expense. The
9 account is a catch-all account for minor accidents,
10 automobile accidents, and sometimes for damages where
11 employee negiligence is involved. For those reasons alone,
12 it would be feasible to argue that the entire amount should
13 be removed from revenue requirement.
14 Q.Are you recommending removal of the entire
15 amount?
16 A.No. I propose using the actual amounts booked in
17 2009 for Inj uries and Damages, net of receivables, for two
18 reasons. First, the 2009 level was the lowest level booked
19 into that account over the past three years, so it is an
20 amount that is reasonably attainable. By including the
21 lowest level incurred during the last three years, it
22 provides incentive for the Company to continue to manage
23 the amounts it spends on Injuries and Damages. Secondly,
24 the amounts booked to Account 925 have been trending
25 downward, from $5.4 million in 2007, to $3.2 million in
CASE NO. PAC-E-10-0710/14/10 ENGLISH, D. (Di)
STAFF
5
1 2008, to $1.9 million in 2009. This downward trend can be
2 attributed to safety measures undertaken by the Company
3 during 2008 and 2009.
4 Q.Briefly describe some of the specific safety
5 measures that were undertaken by the Company during 2008
6 and 2009.
7 A.The safety measures, among other things, ensured
8 that Company policy was developed, effectively communicated
9 to employees, and was being followed at all levels of the
10 organization and that there was sufficient control,
11 monitoring, and correct procedures in place to meet the
12 stated safey performance, which was to be in the top 10% of
13 the Company's peer group. The plan also established a road
14 risk management program to reduce preventable vehicle
15 accidents by 10% below the 2007 and 2008 targets. The plan
16 also included crew audits in the field, managers walking
17 the dock, management's morning stretch and flex and a daily
18 safety briefing at the start of each shift. Quarterly
19 facility audits and monthly crew audits were performed.
20 All deficiencies observed were corrected and responsible
21 employees received coaching, counseling and training.
22 Q.Does the decline in the amounts spent on Injuries
23 and Damages reflect that the plan is working?
24 A.Yes, I believe it does. Therefore, it would not
25 be reasonably prudent to allow the Company to recover in
CASE NO. PAC-E-10-0710/14/10 ENGLISH, D. (Di)
STAFF
6
1 rates any amount that does not take into consideration the
2 Company's recent safety efforts.
3 Q.Please explain the adj ustment to property taxes
4 shown on Exhibit No. 104, line 3.
5 A.The Company has requested to recover in rates an
6 amount it believes will accrue for property taxes for 2010.
7 However, the Company routinely appeals the assessed value
8 of the property that is taxed by the different states in
9 which the Company owns and maintains property. Since 2005,
10 the Company has received refunds from successful appeals
11 totaling over $1.7 million. Because the total accrual for
12 property tax is included in base rates, shareholders
13 receive the benefit of all property tax refunds. Customers
14 who are actually paying the accrued property taxes in their
15 retail rates should receive the benefit of any refunds from
16 the successful property tax appeals. The adj ustment of
17 $288,125 is the average amount refunded to the Company for
18 the tax years 2005 through 2010. This amount is
19 representanti ve of what I believe the Company may receive
20 in refunds for successful appeals of the 2010 tax
21 liability.
22 Q.Please explain the Company's treatment of pension
23 expense in this case.
24 A.The Company requested to recover its 2010 actual
25 cash contributions to the pension plan, instead of the
CASE NO. PAC-E-10-0710/14/10 ENGLISH, D. (Di)
STAFF
7
1 accrued expense calculated under the Statement of Financial
2 Accounting Standards No. 87 (SFAS 87), commonly referred to
3 as the pension expense. This is consistent with prior
4 PacifiCorp rate cases and the Letter of Understanding from
5 the Commission Staff.
6 Q.Can you briefly refresh the Commission on the
7 difference between the two amounts?
8 A.Without getting into the details of how the two
9 different amounts are calculated, which has been rehashed
10 in previous cases, the cash contribution is the actual cash
11 outlay invested into the plan's trust account, while the
12 SFAS 87 pension expense is reflected on the financial
13 statements of the Company as a reduction (or increase) in
14 the Company's earnings. Both amounts are calculated using
15 similar principles, although the rules for calculation are
16 very different. Staff and the Commission have generally
17 supported the use of the actual cash contribution as the
1S starting point for determining an amount to be included in
19 a utility's annual revenue requirement.
20 In this case, the Company reflects a pension
21 expense of $31,800,000 to be recorded on its books for
22 2010, with a cash contribution of $104, SOO, 000 for 2010 on
23 a total system basis. After adjusting the amounts to
24 remove the portion for the mines and to account for just
25 the O&M portion, the Company proposes an adjustment of
CASE NO. PAC-E-10-0710/14/10 ENGLISH, D. (Di)
STAFF
S
1 $47.7 million, as shown on Exhibit No. 105, Column (c),
2 line 11.
3 Q.What is the basis for your adjustment to pension
4 expense?
5 A.At the time of this writing, the 2010 actuarial
6 valuation has not been completed. The Company has not
7 provided any detailed calculations from its actuaries
8 illustrating how the $104.8 million contribution was
9 calculated. Though there is no reason to believe that the
10 2010 contributions are miscalculated, Staff was not able to
11 verify the amounts. Furthermore, the estimated future
12 contributions calculated by the Company's actuaries and
13 provided to Staff confidentially indicate a significant
14 decrease in pension funding in future years. The required
15 contribution for 2010 is approximately twice as much as the
16 contribution for 2009 and estimated contribution for 2011.
17 To include the 2010 contribution amount in rates that go
18 into effect in 2011 and could potentially remain in effect
19 for several years would allow the Company to collect
20 significantly more in revenue than necessary to meet its
21 pension obligations. I have used an average of the
22 proj ected contributions to the pension plan for the period
23 of 2010-2014 as the amount to include in Staff's revenue
24 requirement for pension expense, as shown on Exhibit
25 No. 105 Column (d), line 1. The proj ected future
CASE NO. PAC-E-10-0710/14/10 ENGLISH, D. (Di)
STAFF
9
1 contributions to the PacifiCorp Retirement Plan are shown
2 on Confidential Exhibit No. 106. The Staff adjustment that
3 I recommend for pension expense is $20,875,647 as shown on
4 Exhibit No. 105, Column (e), line 12 and Exhibit No. 104,
5 line 4.
6 Q.Please explain the next adj ustmenton Exhibit
7 No. 104, line 5 labeled as SERP.
8 A.SERP is an acronym for Supplemental Executive
9 Retirement Plan. A SERP is a non-qualified plan for
10 executives of a Company to provide additional benefits
11 above and beyond those covered in more conventional
12 retirement plans to ensure the executive can maintain the
13 same standard of living in retirement. The only active
14 participant in this retirement plan is the President of
15 Rocky Mountain Power, and the Company included $2.6 million
16 on a total system basis to cover this cost. Idaho
17 customers should not be required to pay for additional
18 retirement benefits for executives of a utility above and
19 beyond the retirement benefits that are available to rank
20 and file employees. Because an executive's salary is
21 already higher than the typical employee, and the typical
22 retirement benefits provided are based on the level of
23 wages earned, the executive is already receiving a larger
24 benefit than the other employees. Any additional benefit
25 provided should be paid for solely by shareholders,
CASE NO. PAC-E-10-07
10/14/10 ENGLISH, D. (Di) 10
STAFF
1 especially since an executive's performance is typically
2 based on creating value for the shareholder.
3 Q. Please explain the next adjustment of $33,103,859
4 on Exhibit No. 104, line 6, labeled Incentive Payments.
5 A. Yes, this adjustment represents Staff's
6 adjustment to the Company's proposed level of employee
7 bonuses, ultimately removing 100% of employee bonuses from
8 revenue requirement.
9 Q.Please briefly describe the Company's Incentive
10 Plan.
11 A.The Company establishes an annual amount to be
12 awarded to employees each year. The amount an employee
13 receives is based on an individualized set of goals for
14 that particular employee. If an employee achieves those
15 goals, a bonus is awarded.
16 Q.Why are you proposing to remove employee bonuses
17 from the Company's revenue requirement?
18 A.I am recommending the removal of bonus payments
19 for two reasons. First, because the criteria to receive a
20 bonus is on an individualized basis, it is impossible for
21 Staff to determine if such criteria benefits shareholders
22 or customers. The Commission has previously ruled that
23 incenti ve pay can only be included in annual revenue
24 requirement if it is related to indentifiable customer
25 benefits. If the criteria for an employee to receive a
CASE NO. PAC-E-10-0710/14/10 ENGLISH, D. (Di) 11
STAFF
1 bonus has a shareholder benefit, then the shareholders
2 should bear the cost. Any amount of bonus that ties to
3 operating budgets would have a direct impact on the
4 earnings per share of the Company and therefore would
5 benefit shareholders. However, because of the complexity
6 of the Company's Incentive Plan, there is no way to
7 determine whether the Commission's criteria to include
8 bonuses in revenue requirement has been met. Secondly, I
9 believe that the Commission is cognizant of the public
10 perception of Rocky Mountain Power awarding employee
11 bonuses at a time when it is asking to increase the rates
12 it charges for electricity, and especially when many of its
13 customers are struggling financially. During a time of
14 economic despair throughout Rocky Mountain Power's
15 territory, which is described in Staff witness Thaden's
16 direct testimony and Exhibit Nos. 115 and 116, it is not
17 appropriate to seek recovery of bonus payments from
18 customers. If Rocky Mountain Power believe's that today's
19 financial environment mandates the need for rate increases,
20 those rate increases should be mitigated by a concerted
21 attempt to lower costs and salaries.
22 Q.What is the total percentage of the incentive
23 plan included in an employee's total compensation?
24 A.The Company has proposed to recover $33,103,859
25 for the annual incentive plan and bonuses, which is the
CASE NO. PAC-E-10-0710/14/10 ENGLISH, D. (Di) 12
STAFF
1 2010 budgeted level. Union employees do not participate in
2 the Company's incentive plan. The total 2010 non-union
3 proforma wages and salaries is $201,802,000. This equates
4 to incentives being 16.4% of total wages for 2010.
5 Q.Would you please explain the adjustment to
7
6 Employee Wages listed on Exhibit No. 104.
A.The net effect of this adjustment removes all
8 wage increases awarded by Rocky Mountain Power to its
9 employees during 2009 and 2010, and sets the level of
10 straight-time labor at the January 1, 2009 level.
11 Q.Please briefly descrive the Company's proposal
13
12 for employee wages in this case.
A.Actual December 31, 2009 labor related expenses
14 were annualized to reflect any increases that occurred in
15 2009 as being included for a full twelve months. The
16 annualized 2009 labor expenses were then escalated at
17 ei ther the contractual increase for union employees or the
18 actual increase for non-union employees to reflect a 2010
19 pro forma budgeted amount.
20
21 and 2010?
Q.What types of wage increases were awarded in 2009
22 A. In 2009, non-union employees received a 3.5% wage
23 increase, while the union employees received between 1.25%
24 and 3 percent. In 2010, the non-union employees received
25 an increase of 0.88% while the union employees received
CASE NO. PAC-E-10-0710/14/10 ENGLISH, D. (Di) 13
STAFF
1 between 1.5 and 2. 5 percent.
2 Q.Why do you believe these increases are
3 inappropriate?
4 A.Al though the increases may seem minimal, they
5 occurred at a time of economic distress for Rocky
6 Mountain's customers. Unemployment rates doubled and
7 tripled in many parts of the country, included Rocky
8 Mountain Power's service territory, while wages and the
9 consumer price index remained relatively flat. Americans
10 on Social Security will not receive cost of living
11 adjustments for 2010 and 2011, and most employees with the
12 State of Idaho were forced to take pay cuts. While much of
13 the population struggles, it is not prudent for utility
14 companies to continually grant increases to its employees.
15 Staff believes that during the past two years, Rocky
16 Mountain Power had the opportunity to better control costs
17 and mitigate rate increases. I recommend adjusting
18 employee wages by $14,375,075 (Exhibit No. 104, line 7).
19 Q.Please describe the last adjustment on Exhibit
20 No. 104, line 8.
21 A.The final adjustment I propose is to reduce the
22 MidAmerican Energy Holding Company (MEHC) Management Fees
23 allocated to PacifiCorp. Merger Commitment #28 commits
24 PacifiCorp to limiting the amount of allocations from MEHC
25 to PacifiCorp at $7.3 million, which the Company did in its
CASE NO. PAC-E-10-0710/14/10 ENGLISH, D. (Di) 14
STAFF
1 Application. However, included in the $7.3 million
2 allocation from MEHC is $2.15 million in Supplemental
3 Executive Retirement Plan contributions and bonuses to
4 employees of MidAmerican. I remove this amount as a
5 logical continuation of adjustments. Because I recommend
6 removing bonuses and SERP contributions for Rocky Mountain
7 Power employees from customers' retail rates, then the SERP
8 contributions and bonuses for employees of MidAmerican
9 should also be removed. Exhibit No. 107 illustrates how
10 the $7.3 million cap is affected by this adjustment and
11 shows my adjustment of $1,100,635.
12 Q.Does this conclude your direct testimony in this
14
13 proceeding?
15
16
17
18
19
20
21
22
23
24
25
A.Yes, it does.
CASE NO. PAC-E-10-0710/14/10 ENGLISH, D. (Di) 15
STAFF
Rocky Mountain Power
Idaho General Rate Case - PAC-E-10-7
Summary of D. English Adjustments
Adjustment System Amount Idaho Allocation
1. Imputed Revenue $142,069 $7,826
2. Injuries and Damages $(1,603,785)$(90,728)
3. Property Taxes $(288,125)$(16,299)
4. Pension Expense $(20,875,647)$(1,200,000)
5. SERP $(2,600,000)$(149,500)
6. Incentive Payments $(33,103,859)$(1,903,000)
7. Employee Wages $(14,375,075)$(826,500)
8. MEHC Affiliated Management Fees $(1,100,635)$(62,264)
Exhibit No. 104
Case No. PAC-E-I0-7
English, D., Staff
10/14/10
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Case No. PAC-E-IO-07
Exhibit No. i 06 prepared and sponsored by
Donn English is Confidential and only
available to those persons who have signed
Protective Agreements
Rocky Mountain Power
Idaho General Rate Case - PAC-E-10-7
Affiliated MEHC Management Fees
Total Invoiced and Booked ATL
SERP
MEHC Bonus
MEC Bonus
Aircraft
Aircraft - Commercial Equivalent
OTHER
322,086
1,700,237
131,342
700,336
139,748
5,359,281
8,353,030
Company Adjustment to get to Commitment 9
Company Proposed ATL Billng
(1,053,029)
7,300,000
Staff Adjusted ATL Billng (Removal of SERP and Bonuses)6,199,365
Staff Adjustment to Company Case (1,100,635)
Exhibit No. 107
Case No. PAC-E-I0-7
English, D., Staff
10/14/10
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 14TH DAY OF OCTOBER 2010,
SERVED THE FOREGOING NON-CONFIDENTIAL DIRECT TESTIMONY OF
DONN ENGLISH, IN CASE NO. PAC-E-1O-07, BY MAILING A COPY THEREOF,
POSTAGE PREPAID, TO THE FOLLOWING:
TED WESTON
ID REGULATORY AFFAIRS MANAGER
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
(FED EX)
E-MAIL: ted.weston(ýpacificorp.com
E-MAIL: ONLY
MARK C MOENCH
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
E-MAIL: mark.moench(ýpacificorp.com
daniel. solander(ýpacificorp.com
RANDALL C BUDGE
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
(FED EX)
E-MAIL: rcb(ýracinelaw.net
E-MAIL: ONLY
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: jim.r.smith(ýmonsanto.com
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
(FED EX)
E-MAIL: tony(ýyanke1.net
PAUL J HICKEY
HICKEY & EVANS LLP
1800 CAREY AVE., SUITE 700
PO BOX 467
CHEYENNE WY 82003
(FED EX)
E-MAIL: phickey(ýhickeyevans.com
E-MAIL: ONLY
KATIE IVERSON
BRUBAKER & ASSOCIATES
E-MAIL: kiverson(iconsultbai.com
ERICLOLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
(FED EX)
E-MAIL: elo(iracinelaw.net
CERTIFICATE OF SERVICE
TIM BULLER
JASON HARRS
AGRIUMINC
3010 CONDA RD
SODA SPRINGS ID 83276
(FED EX)
E-MAIL: tbullerrfagrium.com
j aharrisrfagrium. com
BENJAMIN J OTTO
IDAHO CONSERVATION LEAGUE
710 N 6TH STREET
PO BOX 844
BOISE ID 83702
(HAND CARRIED)
E-MAIL: bottorfidahoconservation,org
E-MAIL: ONLY
DR. DON READING
E-MAIL: dreadingrfmindspring.com
MELINDA J DAVISON
DAVISON VAN CLEVE, P.C.
333 SW TAYLOR, SUITE 400
PORTLAND, OR 97204
(FED EX)
E-MAIL: mjdrfdvclaw.com
RONALD L WILLIAMS
WILLIAMS BRADBURY, P,C.
1015 WHAYS STREET
BOISE ID 83702
(HAND CARRIED)
E-MAIL: ronrfwiliamsbradbury.com
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
(HAND CARRIED)
E-MAIL: bmpurdyrfhotmail.com
Jl~.\(&'
SECRETARY
CERTIFICATE OF SERVICE